INTRODUCTION

CLOVER BROKERS encourages the highest professional and ethical standards in the insurance industry.
CLOVER BROKERS looks to all its employees, to meet these standards and to maintain the reputation of the company by following this code of ethics and conduct. It sets down the principles which all employees of the group should follow in the course of their professional duties.
EMPLOYEES are obliged to comply with this code. If They do not comply, this may result in the company taking disciplinary action against the employee.

GENERAL RULES

1-1 WE WILL PERFORM OUR DUTIES TOWARD OUR CLIENTS, MEMBERS OF THE PUBLIC, FELLOW AGENTS OR BROKERS, AND INSURERS WITH INTEGRITY. 1-2 We will Avoid any Conviction of a criminal offense which brings into question our professional integrity or competence to act as a broker, even if unconnected with our work as a broker

RELATION WITH CLIENTS

2-1 We Will Not Taking improper advantage of a client’s inexperience, lack of education, youth, lack of sophistication, un-business-like habits or ill health.

2-2 We Will Not Misappropriating or dealing dishonestly with our client’s money or other monies deemed to be held in trust by us.

2-3 We shall describe the mechanism for premium payment, the importance of paying on the set dates and the effects which may result from failing to abide by such dates;

2-4 WE OWE A DUTY TO THE CLIENT TO BE COMPETENT TO PERFORM THE SERVICES WHICH THE AGENTS OR BROKERS UNDERTAKE ON THE CLIENT’S BEHALF

2-5 WE WILL SERVE OUR CLIENTS IN A CONSCIENTIOUS, DILIGENT AND EFFICIENT MANNER AND SHALL PROVIDE A HIGH STANDARD QUALITY OF SERVICE.

2-6 WE WILL BE BOTH CANDID AND HONEST WHEN ADVISING CLIENTS

2-7 Recommendations to clients should be complete, open and clear. We must indicate in detail, the facts and assumptions upon which our recommendations are based. We must study the risk in sufficient detail to provide the client with sufficient information with which to make an informed decision.

2-8 We have an obligation to inform our clients at all times about all aspects of the insurance products they have purchased including any changes affecting a policy which occur during the policy term.

2-9 We shall give technical advice and consultation, inform a customer with the best conditions and prices of the companies, maintain and incorporate the supporting documents in duly organized records, negotiate for its interest, be represented before the company, not receive any commission for the negotiations;

2-10 We shall observe the interests of a customer, whether in comparing the conditions, prices and scope of insurance coverage or in terms of preferring to deal with a company other than another one, it shall not recommend or prefer a company just because it provides a larger commission to Clover Brokers;

2-11 Clover Brokers shall ensure that a customer recognizes and understands the type of the provided service and the nature of the relation between them and that the insurance document meets the requirement of the customer;

2-12 We shall notify the customer of all details of the insurance document in terms of the insurance coverage scope, customer tolerance (if any), liquidation value, prior to the due date or the occurrence of the insured danger, and any conditions, exceptions or restrictions on the insurance document;

2-13 We shall set out the importance of disclosing the basic and fundamental information, upon submitting the insurance application, and the implications of concealing or providing any inaccurate or incorrect data or documents, indicating the full liability for such data and information;

2-14 We shall send the insurance documents to the customers without unjustifiable delay, attaching thereto a notification of the necessity of a careful reading of the document,

2-15 We shall set out the procedures to be implemented by the customer, once the insured danger occurs, and assist in the negotiations made with the company on the claims resulting from such occurred danger; it shall notify the customer forthwith of the company’s decision on accepting or refusing to provide the insurance coverage of such claims;

2-16 We shall inform the customer in writing 20 business days prior to the expiration of the insurance document of its expiration date to demonstrate in writing its desire for: a) Renewing the insurance document with the same insurance company or not; b) Renewing the insurance document with the same insurance broker, under the same terms and conditions, with the same company and in different conditions or with another insurance company according to other offers presented thereto by the insurance broker;

2-17 We will not be engaged in any “tied selling” practice.

2-18 It shall sign an authorization written by each of its customers to perform the insurance brokerage business according to the prepared form, as approved by the Insurance Authority, provided that it shall, particularly, state that: a) Clover Brokers shall have the powers to communicate with any company licensed by the Authority or any licensed company determined by a customer; b) Clover Brokers shall have the responsibilities and powers of an insurance broker with respect to the procedures for claiming the indemnity which may be due to a customer upon informing the same of the insured accident;

2-19 Clover Broker's freedom of withdrawing or cancelling the authorization shall not be restricted, it shall not, in addition, bear any resulting financial encumbrances;

2-20 A letter of authorization shall be required from any prospective client in order to provide quotations for insurance, the letter shall be worded clearly and specifically regarding this purpose and should not be used unfairly against the present agent or broker for any other purpose.

2-21 WE WILL HOLD IN STRICT CONFIDENCE ALL INFORMATION ACQUIRED IN THE COURSE OF THE PROFESSIONAL RELATIONSHIP CONCERNING THE BUSINESS AND AFFAIRS OF A CLIENT, AND WILL NOT DIVULGE ANY SUCH INFORMATION UNLESS AUTHORIZED BY THE CLIENT TO DO SO, OR REQUIRED BY LAW TO DO SO OR WHERE WE MUST DO SO IN CONDUCTING NEGOTIATIONS ON BEHALF OF THE CLIENT.

RELATION WITH REGULATORS AND THE LAW

3-1 We will operate within the Law and Within the spirit of the Law, at all times.

3-2 We will deal with regulators in an open, transparent and co-operative manner and meet any requirements correctly made of them.

RELATION WITH THE PUBLIC

4-1 WE WILL ENCOURAGE PUBLIC RESPECT FOR AND TRY TO IMPROVE THE PRACTICE OF OUR PROFESSION.

4-2 WE WILL MAKE SERVICES AVAILABLE TO THE PUBLIC IN AN EFFICIENT AND CONVENIENT MANNER WHICH WILL COMMAND RESPECT AND CONFIDENCE AND BY MEANS OF WHICH IS COMPATIBLE WITH INTEGRITY AND EFFECTIVENESS.

4-3 WE WILL ASSIST IN MAINTAINING THE INTEGRITY OF THE PROFESSION AND WILL PARTICIPATE IN ITS ACTIVITES.

4-4 WE WILL ASSIST IN PREVENTING THE UNAUTHORIZED PRACTICE OF THE PROFESSION.

4-5 OUR CONDUCT TOWARDS OTHER LICENSEES, MEMBERS OF THE PUBLIC AND INSURERS SHOULD BE CHARACTERIZED BY COURTESY AND GOOD FAITH.

CONFLICT OF INTEREST

5-1 Avoid Conflict between any competing interests, or the interests of any associated company, person or group of persons, and our duties to all clients

5-2 Avoid Conflict between any competing interests of one or more clients, stepping aside in one or all matters if such conflict cannot be resolved.

5-3 Not provide or accept money, gifts, entertainment, loans or any other benefit or preferential treatment from or to any existing or potential clients or provider, other than occasional gifts, entertainment or remuneration, which are provided as part of accepted business practice, and which are not likely to conflict with duties to clients.

COMPLIANCE WITH ANTI MONEY LAUNDERING OBLIGATIONS

Clover Brokers shall comply with the provisions set out by the local authority where we are present concerning insurance broker regulations in particular those dealing with anti-money laundering and combating terrorist financing in the insurance industry.